|Received:||7/4/2006 7:23:20 PM|
|Subject:||Business Opportunity Rule|
|Title:||Notice of Proposed Rulemaking|
|CFR Citation:||16 CFR Part 437|
Comments:Thank you for your effort to safeguard the public from fraud. These companies hurt legitimate businesses, like mine. Here are my concerns about the proposed rule: (1) It is not fair to give a list of all litigation. The only cases applicable would be those judged against the company. And, whose cases are we talking about: my business, the team I work with, the company supplier that pays us, or all the stores that have contracts with my supplier? That could be a mess! I can see prospects just throwing up their hands and saying, "Forget it!" when they see all this info. (2) Again, to give disclosures for every income claim related to my business would overwhelm people with information. Besides this, there are multiple variables like bonusus, trips, etc for each level. How would you even organize all this information? (3) I object strongly to providing personal financial information to back up an income claim. This is an invasion of privacy. Besides, what I make has no bearing on what the prospect will make. It's quite possible for him to make more than me.Also, I can see prospects backing off just because they don't want their information publicly available, in turn. (4) I have three objections to prospects being required to wait seven days. First, the prospect is an adult. If he needs time to think about it, he is able to say so. Second, my business has no territories so if I prospect someone while flying to Miami and I return home in three days, how am I supposed to sign him up? Third, that week of waiting costs the prospect money. Other prospects that I would sign up under him in those days will be assigned to someone else. That could lose him significant income down the line. (5) Regarding the idea of giving 10 references, I have several objections. First, this violates the privacy of those businessmen. I would be upset to find myself on such a list. Next, it could cost me money because the prospect, who I have done all the ground work on, could sign up with one of those other businessmen! The fact that I and others like myself don't work assigned territories makes this even more complicated. Who goes on the list? The team I work with is not local: they're in Florida, Michigan, and North Carolina. If I give local info on local businessmen, that tells the prospect nothing about how he will do on MY team, because individuals and teams are free to develop their own strategies. Thank you for the opportunity to express my opinion. I wish you good luck in drafting a rule that will be effective, fair, and not onerous to honest businesses. It won't be easy. I appreciate your efforts.